1. FCC-DOL Joint Workshop on Communication Tower Safety RFI Panel February 11, 2016 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 1

2. 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 2 Selection of Comments Received in Response to OSHA Request for Information Communication Tower Safety OSHA-2014-0018

3. Timelines “The biggest problem is the rush carriers put on GCs. We have a couple weeks where we might not have any work. Then all of a sudden. We get four sites in and companies … expect these sites to be completed within a matter of days. We have to push our guys to the limits sometimes working two weeks straight 10-12 hours a day.” 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 3

4. Timelines “[M]ost safety issues are directly a result of pressure from the wireless carriers to get the projects done in a very short time frame. Even though the field crews go through all the OSHA, Comtrain and other safety training, they feel they need to take short cuts to get the job done by the due dates specified by carriers. This means they do not always adhere to the safety regulations purposely or are too exhausted and overlook steps to insure theirs and others safe working conditions on job sites.” 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 4

5. Obstructions “The placement and positioning of equipment on the tower, however, probably has the greatest impact on climber’s ability to safely navigate the natural hazards of our work. Obstruction of tower integrated safety components is certainly one of the more common examples of this. Mounts themselves are often heavily crowded with equipment and cabling in a configuration that can require climbers to take greater risks simply to access the equipment they need to work on....” 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 5

6. Obstructions “… T-Boom style mounts, as an example, often greatly increase the difficulty of accessing the equipment by requiring the climber to execute a balancing act along one, often round, steel member to reach the equipment - then to hang up to six feet below the mount in order to access cabling and connections. Finding a means of creating greater ease of access to the equipment once on the tower would mitigate some of the risk inherent in working on these structures, further allowing the workers to focus their attention on less controllable hazardous elements.” 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 6

7. Training “The… issue is the use of a copier to make everyone a certification. Every employee I hired would submit a certification that was copied from someone else's certification and their name added. I had 8 companies tell me that they send one person to the class and then everyone is certified in their company with the use of a copier.” 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 7

8. Lack of Experience “I was sent to sweep test a [company’s] site with two climbers. When we got to the site, one of the climbers had two weeks experience but had only climbed one time and the other climber had been hired the day before. Climber B (the one hired the prior day) decided he didn't want to do this job anymore and quit on site...” 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 8

9. Lack of Experience “… Climber A with the two weeks experience belted up, and started climbing but had trouble with his safety climb about 60' up the tower. Climber B exhausted himself trying to figure out how to get his safety climb sleeve past the bracket and I had to rescue Climber A from 60'. In order to finish the job, I had to let the [company] rep use the sitemaster to test while I then climbed the tower to ~160', changed the TMA and completed the tower side of the sweep process. This was a regular occurrence.” 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 9

10. Weather “[W]e work in conditions that other construction workers with ‘safer’ jobs don’t. EVERYONE climbs in the rain even if its ‘policy’ not to. Refuse to climb in harsh weather and you will never go anywhere in this business.” 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 10

11. Weather “Weather is also a major contributor to safely working on towers. Contractors in the north deal with every weather condition out there during the year. There doesn’t seem to be any standards available out there as to limits to temperatures, wind or snow / ice accumulations on the towers. It is basically up to the field employees and their managers to decide when employees should be climbing or not.” 2/11/2016 FCC-DOL Joint Workshop on Communication Tower Safety 11